PFISpeed fined by EPA for selling Hondata

In reply to 03Panther :

"Executive Order".

It essentially says "we the California government allow the following modifications to be installed on the following vehicles with no repercussions".

In reply to Pete. (l33t FS) :

Really not that hard to do.  Most of the intakes are free, along with cat back exhausts, suspensions, cams, etc.  Some of the tunes are EO qualified as well.  You can drop an e-rod crate LS3 into anything it fits into.  This isn't a big deal, basically all the stuff I've done to my 911, KTM and corrado are legal emissions wise.

For the purposes of our discussion, an EO means that a part has been proven not to affect emissions and it's part of the California emissions program. CA does visual checks to make sure that a car is unmodified - and if it is modified, that the parts installed have an EO. Kind of a pain but it does give a way for parts to be developed and approved, which makes it preferable to a blanket ban. This visual check is being done at the individual inspection level (including roadside) but the EPA crackdown is effectively implementing it country-wide at the vendor level when I think about it.

It's currently the only mechanism available for proving that emissions are unchanged. In theory, you could go through the testing and not bother with the EO paperwork. The EPA is working on formalizing this, but it's kind of a goofy thing because why would you lock yourself out of the CA market if you've paid for that testing?

Anything after the cat is not involved in emissions, so it's "free" as noted. The intake is a little less clear. One of our EOs is for a replacement pipe going into the stock airbox. We didn't have to do any testing because it's borderline on if it's needed, so we got an engineering assessment EO which basically says "yeah, this is fine". But without it, the car would probably fail a CA visual inspection.

You cannot drop an E-ROD crate LS3 into anything it fits into. The EO for that applies to 1995 and older cars only. It cannot cross the OBD-II line due to the evaporative emissions components that would entail. Not a lot of people are aware of this, but it's why the only Miata in California that legally runs this engine is very specifically a 1995.

You can search the EO database on the ARB (Air Resource Board, the California is implied in California) website. There are a surprising number in there and they go back a long way.

In reply to Keith Tanner :

Didn't know that about the e-rod LS3.  At that point I suppose as long as you've brought everything else over from that same year LS3 car into your 1996+ you're fine...

docwyte said:

In reply to Keith Tanner :

Didn't know that about the e-rod LS3.  At that point I suppose as long as you've brought everything else over from that same year LS3 car into your 1996+ you're fine...

That's another way to do it.  The OTHER legal LS3 Miata in California did it that way. But you're getting pretty deep into the car at that point and it's not easy because you're into the gas tank and the rest of the evaporative systems. And you'd probably have to start with the engine, PCM, etc from the donor instead of trying to add 2011 Camero bits to an E-ROD unless you got approval from the BAR ahead of time.

Here's the original LS3 E-ROD EO for those who are interested. http://ww2.arb.ca.gov/sites/default/files/classic/msprog/aftermkt/devices/eo/d-126-30.pdf 

Keith Tanner said:

You can search the EO database on the ARB (Air Resource Board, the California is implied in California) website. There are a surprising number in there and they go back a long way.

I actually went and tried to do that a couple months ago... to see if I could build a CARB/EPA-legal ClubTR TimeAttack car.

Did I get the wrong site?  Because the site I found regurgitated a huge amount of data in a poorly formatted, up searchable mess.

I didn't say it was EASY to search. The problem is that it's not listed by application, it's basically listed by product type or manufacturer. That's because a lot of EOs cover a wide range of applications - something the ARB is actually trying to reign in a bit. And because that's how the ARB categorizes things.

But you can make some headway by doing things like searching for all turbochargers, then control-F to find references to "Miata". Then you have to find out if the products are still available, as the EO is not tied to actual production. That Miata turbo search gets you one belonging to Bell Engineering (out of business) for an Aerodyne turbo (NLA for a very, very long time), Bell Engineering (still out of business) for a Garrett kit, BBR for a 1.6 kit (that should be available but you may have to order from the UK), GReddy for a 1.6 kit (NLA) and some other company called Soaring MX-5 or something like that.

So if you're looking for a specific part for your car, you may have to do a little legwork. If you're looking for all parts that fit your car, you'll have to do a lot of legwork. Especially when you're dealing with something like an MSD ignition system that has a big fat blanket EO that covers things like "2003 and older vehicles".

I enjoy reading through it casually because there's some weird stuff in there.

In reply to Keith Tanner :

Ok, good to hear I wasn't off in 1990 Databaseland... by accident.

I have an inarticulate frustration with this, despite understanding how "we" ended up in this place in time/space/condition... and having spent some time to make me value clean air.

edit:   
it's also interesting that the market so far hasn't realized that EO's have value after bankruptcy?  Or maybe, could have value after bankruptcy.  There's a... well, not 'similar'... but the FAA has the STC ('Special Type Certificate') system... and the aviation market has realized the importance of acquiring that IP, if a new business can figure out how leverage it at a lower cost compared to the originator (or, even 'most recent owner').  That doesn't seem to be the case here... or it's a short-coming of CARB's current EO system

All of which is to say... I see significant shortcomings to pinning our hopes/dreams on RPMact... because I don't see it addressing any of this, imho.

RPM Act does not address any of this for street cars because that isn't what it's intended to address. It  legitimizes dedicated race cars, making the "competition use only" thing something real. But it will only apply to dedicated race cars, not street driven Miatas that autocross a few times a year and need 300 hp to do it.

There's no reason for the ARB to have a handy list of EOs by application because that's simply not how they're inherently laid out or even written. Their database does not include the make/model/year/submodel/engine/etc. It'll take someone downloading the entire database and categorizing it to make it searchable that way - and it's hard to come up with the business case for that specific startup unless you get a kickback from parts manufacturers for driving sales their way. Which could potentially work but it's going to take a lot of hand sorting.

I don't know if EOs can be transferred. They're tied to a very specific product, so you'd have to take over production of that product while staying within the description of the EO. That EO for Aerodyne turbos on a 1.6 Miata, for example, is no good since there is no longer any such thing as an Aerodyne turbocharger. But an EO for a Garrett turbo on a 1.6 Miata, that could potentially be transferred as long as everything was as described.

Keep in mind that the California EO program was a way to implement California's specific inspection program. The fact that it's the only recognized way to certify a part does not adversely affect emissions is a bit of a side effect, and the EPA and friends are working on other options. They will all involve basically putting a car through the same tests it would have received when it was new, but the ARB is also looking at categorizing the tests a little differently so that an air intake won't have to undergo the same testing as a supercharger (which has to undergo more tests than a turbo does already). Those who have been working with the SEMA lab over the years have already effectively been guinea pigs for this, and it's working IMO.

It's all quite simple, really.

- cars have come from the factory with emissions controls for about a half century now and have had onboard monitoring systems for a quarter century.
- you are not allowed to sell things that bypass/disable/defeat these controls or monitoring systems or to remove them.
- you can modify your engine as long as you can prove that the modifications don't adversely affect emissions, and you can sell parts that do the same. It is possible for an individual to do this but is expensive because the tests are a lot more thorough than sticking a probe up a hot tailpipe. The best way to prove this is to get an EO for the part from California.
- there is no such thing as "for off-road use only" until the RPM Act is passed. There never has been but it was accepted until it was abused. If it is passed, there will have to be checks in place to ensure that these parts are only sold to/used on true, dedicated competition cars.

So who's going to take one for the team and report Vermont Sports Car/Subaru USA for altering and/or removing emissions equipment from street registered cars? 

https://www.subaru.com/content/subaru/en/motorsports/cars/rally.html

In reply to _dave :

Stock engine ECU and probably retains cats as rally cars do. As long as the intake restriction doesn't affect emissions - and Subaru definitely has the testing facilities - that can be completely legit.

https://vtcar.com/cars/vt20r/

Exhaust System
Vermont SportsCar Custom Exhaust Manifold
Vermont SportsCar Stainless Steel 3-inch Quick-Change System

Engine
Horizontally Opposed 4-cylinder
Turbocharged and Intercooled
Garrett Motorsport Turbo
Approx. 330 bhp and 400 lb-ft torque
(With an ARA OPEN 4WD Class-mandated 34mm Restrictor and 27psi Boost Limit)
Garrett Motorsport Turbo

Engine Management
Cosworth Pectel SQ6M ECU

Fuel Cell
Under-floor FIA FT3.5 Fuel Cell (75+ Liters)

I don't think the stock EVAP system made it over...

Notice in the engine is stated as "Horizontally Opposed 4-cylinder".  I would be surprised if there are any OEM parts remaining on that engine, it's a billet block, billet head, etc. bespoke design.  5+ years ago VSC ran subaru engines but not anymore.

“People sometimes say ‘what a waste! You strip the whole car? Why don’t you just start with a bare shell direct from the factory?'” Chris added later, in an emailed statement. “For rally cars in the USA, the car needs to be street legal, which means it’s registered/insured, which means it needs a VIN,” he continued. “Getting a bare shell from Japan would not have VIN. For our GRC cars, which do not need to be street legal we can (and do) use bare shells supplied from Subaru,” he said.

https://www.motorbiscuit.com/vermont-sportscar-its-what-makes-a-subaru-a-subaru-rally-car/

From 2015, but according to what PFI, Evans Tuning, Cobb, and others have been accused of, that is a clear admission of guilt.

Ah, I missed the link for specs on my phone. Only saw the blurb. Yeah, that's pretty likely not going to pass the EPA regs as written unless there's been a lot of work done with that ECU. It's not impossible and like I said, Subaru definitely has the resources to do the testing. IIRC there is one test cell at the SEMA lab and little Mazda has something like 31. Remember, you don't need to retain the stock evap system if you can prove the one you have in place still works - and I don't know why you couldn't actually bring the evap system over to the rally car, it just means a bit more plumbing into the fuel cell.

So this is a legit competition car, but one that runs on public roads. I don't know if they need a special plate to do so - I know that we were issued special plates for the Targa Newfoundland so that cars that were not Canada-registered could compete. They were good for a week. In this case, the EPA is probably going "yes, that is a legitimate competition car" and note specifically that Subaru is not selling the parts, so it's not liable to open an investigation. But if someone drops a dime on Vermont Sports Cars, the EPA may be required to investigate and that might have all sorts of knock-on effects.

I'm not sure what the point being made here is, honestly. You want this shut down? It's not fair? The enforcement did not land fully baked and it's evolving?

No, I don't want to see it shut down. It was an observation on a particular class of competition vehicles that could face issues in the near future. I think the correct solution is for the sanctioning bodies to work with venues to allow participation for non-registered vehicles. Hopefully that does not severely impact or limit the scheduling/locations available for ARA and NASA.

Reading through the past several pages of this discussion has made me realize that in the immediate future I don't need to address engine parts to get an old project back on the road; a better use of those funds is a tow vehicle, trailer, and committing to track only use with a roll cage/other safety equipment. 

In reply to _dave :

Given that stage rally cars are driven on public roads during the course of the event, they kind of have to be registered as road vehicles.

That said, I've stuck dealer plates on pure race cars to drive them on the street for the purposes of evaluation and repair.

Rally cars are an odd case for pure competition vehicles. I don't think any other type needs to use public roads. WRC championships have been (almost) lost because a car was not roadworthy enough to get to service in the eyes of the local constabulatory. Marcus Grunholm might be willing to drive on three wheels, the UK police are not so accommodating. That would have cost Marcus the championship if Sainz hadn't broken down within sight of the finish.

I suspect they will have to retain their emissions components in the future. I have no idea how grandfathering would work. Maybe a 5 year grace period. 

OEM's can have manufacturer plates, which means you can get an emissions except sticker to put under the hood.  All test cars have them, even if they are some of the cleanest cars on the planet.

Subaru can certainly do that.

IIRC, rally cars get a motorsports exemption in Euro countries.

They're also a lot less wild and wooly than US stage rally, with respect to allowances.  Not sure if the modern crop of WRCars and R3s (or whatever the top tier 2wd class is called now) have to be homologated, but the Group A and N stuff sure did.  If it wasn't in the official technical papers submitted to the FIA, you couldn't do it.

i've heard of people being excluded because their clutch disk was found to be a few grams overweight.

Keith Tanner said:

Rally cars are an odd case for pure competition vehicles. I don't think any other type needs to use public roads. WRC championships have been (almost) lost because a car was not roadworthy enough to get to service in the eyes of the local constabulatory. Marcus Grunholm might be willing to drive on three wheels, the UK police are not so accommodating. That would have cost Marcus the championship if Sainz hadn't broken down within sight of the finish.

I suspect they will have to retain their emissions components in the future. I have no idea how grandfathering would work. Maybe a 5 year grace period. 

Pittsburgh Vintage Grand Prix runs public roads, but the vintage thing might not give the EPA a care. Just tossing in an exception to your thought.

In reply to preach (fs) :

Indycars run on street courses all over North America, I don't think it's a problem if the streets are closed.

In reply to adam525i :

Exactly... and stage rally transits on roads open to the public.

Safari had its TIMED STAGES on roads open to the public, too.

Closed roads are not public roads, they're temporary private race tracks from a legislation standpoint.